Background Screening Policy
We recognise that our people is one of our best assets and it is by working together that we can all help to grow our business and ensure both individual success and the Company’s success in the future. We are keen to select the people best qualified and most suited to any vacant role to join our team, whilst ensuring we fully comply with UK legal requirements and industry best practice.
We expect our employees to maintain the highest standards of professionalism, honesty and integrity. To reflect this, our on-boarding process includes a number of employment and background checks. These checks ensure we remain compliant with relevant legislation and regulation and protect our customers, clients and the Company as a whole.
Hydrocare Leisure Limited is committed to fair treatment and the equality of opportunity in employment and to the recruitment of a diverse workforce based upon individual merits, regardless of age; disability; gender reassignment; marriage and civil partnership; pregnancy and maternity; race; religion or belief; sex and sexual orientation.
James and Julie Phillpot
Directors Hydrocare Leisure Limited
The Background Screening Policy incorporates both pre- employment and on-going employment checks that need to be undertaken throughout the time individuals are employed by Hydrocare Leisure Limited.
- Disclosure and Barring Service (DBS)
The Disclosure and Barring Service (DBS) is a government agency responsible for providing information, ‘disclosures’, to employers with regard to the past criminal record of an individual.
For the majority of positions, Hydrocare Leisure will only ask about “unspent” convictions, as defined in the Rehabilitation of Offenders Act (1974). The nature of our business means that some staff (e.g. those working in the Engineering Team) can only complete ‘customer jobs’ at customers’ homes, in schools or commercial premises. Often the work requires members of our team to enter the premises and/or work within the grounds of the home, grounds or premises and work unsupervised.
Our customers may include vulnerable adults, victims of crime or children left unsupervised in private homes, schools or commercial premises. We have a duty to respect and protect their interests as well as those of our staff. Employees working at customers’ homes, in schools or commercial premises assume positions of trust and therefore no conviction can be considered “spent”. Applicants to these positions will be asked to disclose information about any criminal conviction, including spent sentences, cautions and bind-over orders.
Applicants who are deemed unsuitable to undertake a position in the light of the contents of a disclosure will receive a written explanation of Hydrocare Leisure’s decision. Failure to reveal information that is directly relevant to the position sought or failure to comply with the request for DBS checks could subsequently lead to Hydrocare Leisure rejecting an application or the withdrawal of an offer of a position. Hydrocare Leisure undertakes to discuss any matter revealed in a Disclosure with the applicant before withdrawing an offer of a position.
Applicants who are not able to provide a Disclosure before the commencement of a position may be allowed to work provisionally for a limited period of time under the supervision of another Hydrocare Leisure employee with the appropriate checks in place.
Disclosure information will only be seen by those who need to see it as part of the admissions process, and this information will be treated confidentially, sensitively and in accordance with Hydrocare Leisure’s Data Protection Policy.
Having a criminal record will not necessarily be a bar to working at Hydrocare Leisure. The decision will depend on the nature of the position that is being offered and the circumstances and background of any offences committed.
Whilst a disclosure does not technically expire, Hydrocare Leisure have made a business decision to repeat this check on staff in relevant roles every 1-3 years. This is because the disclosure is only valid at the point of issue and we are not informed when new ‘spent’ or ‘unspent’ convictions would be added to a disclosure.
As an organisation using the Disclosure and Barring Service, Hydrocare Leisure complies fully with the DBS Code of Practice. (See Hydrocare DBS Criminal Records Policy for full details).
- Background Screening
All applicants deemed successful at interview will be subject to a number of checks, determined by the position for which they have applied. Where an applicant is an existing employee of Hydrocare Leisure but applying for a new role within the Company, Hydrocare Leisure reserves the right to request an up-to-date employment check (full or partial) completed, especially if the new position is substantially different or the employee will come into contact with vulnerable adults or children, in which case new checks may be requested.
These may include:
- Identity check
- Eligibility to work in the UK
- Pre Placement Health Questionnaire
- Driving licence checks
- References and employment history
- Professional registrations and/or qualifications
Failure by an applicant or existing employee to provide accurate information in a timely manner is a serious matter. Where it is found that an individual has declared inaccurate or fraudulent information, or refused to comply with the request for background screening, may disqualify them from position or result in disciplinary action being taken in line with Hydrocare Leisure’s Employee Disciplinary Policy.
- Fleet and Driver Checks:
If an employee’s role within Hydrocare Leisure requires them to be able to drive a Company vehicle, it will be a condition of their employment that they hold, and continue to hold, a current full UK driving licence. Employees may be required to produce their original licence at any time, which must be produced directly upon request.
Before driving on Company business or in a Company vehicle, all employees and any authorised drivers or employees driving privately owned vehicles on Company business are required to submit an online declaration for permitting the Company to seek details of their driving entitlements electronically from the DVLA. Mandates remain valid for three years allowing checks at a frequency determined by the Company based upon a driver’s endorsement history. As a minimum, this check will occur annually.
Any changes to an employee’s license, e.g. address; endorsements; penalty points; or pending motoring prosecution or ban must be notified to the Company immediately. It is a legal requirement that a driving license show the driver’s current address. Any licenses which do not display the same address as the employees HR record will not be accepted.
In the event that an employee loses their entitlement to drive and therefore their driving licence for whatever reason, the Company reserves the right to terminate employment where driving is a requirement of the role.
A conviction for drink driving or driving whilst under the influence of drugs, whether on Company business or not, is viewed by the Company as a serious breach of its Drugs and Alcohol Policy. This could constitute gross misconduct and an employee may be subject to dismissal. If an employee cannot perform their job satisfactorily as a result of losing their driving license, the Company may institute formal disciplinary procedures which could also lead to dismissal.
Failure by an applicant or existing employee to provide accurate information in a timely manner is a serious matter. Where it is found that an individual has declared inaccurate or fraudulent information, or refused to comply with the request for DVLA screening, may disqualify them from position or result in disciplinary action being taken in line with Hydrocare Leisure’s Employee Disputes Policy.
See Hydrocare Company Vehicle Policy for further details.
- Data Protection
Background screening information will be used and processed solely for the specific purpose for which it was requested and for which the candidate or employees full consent has been given.
Background screening information will remain confidential and secure and is only passed to those individuals who are authorised to receive it in the course of their duties as part of recruitment decision-making process or for the administration of the processes related to these activities. Authorised individuals would be a member of the HR team, the recruiting manager, the company directors and the individual concerned.
Records relating to background screening will either be held by a verified third party and retained in line with their retention schedule or by Hydrocare Leisure and be placed securely in our HR information systems. Records will be destroyed in accordance with the Hydrocare Leisure Retention Schedules.
Inappropriate access or disclosure of employee data constitutes a data breach and should be reported in accordance with Hydrocare Leisure’s data protection policy immediately. It may constitute a disciplinary offence, which will be dealt with under Hydrocare Leisure’s Employee Disciplinary Policy.
Background Screening Policy
Hydrocare Leisure Limited commits to fulfilling their legal obligations as set out by all current legislation relating to background their Criminal Records Check Policy. This will include, but will not be limited to, the following:
- the Rehabilitation of Offenders Act (1974)
- the Health and Safety at Work Act (1974)
- the Management of Health and Safety at Work Regulations (1999)
- Immigration, Asylum and Nationality Act (2006)
- General Data Protection Regulations (2016)
Company policies are communicated and made available to all staff and discussed at launch during team meetings. All staff have access to all Company Policies which are stored electronically (HERE)
All Company Policies are approved by the Directors of Hydrocare Leisure Limited. Each policy is reviewed at least annually to ensure that we respond to clients, business strategy, legislation and any standards or codes of practice determined by the market.
This policy must be strictly adhered to by every employee. Any breaches of this policy will be investigated and, where appropriate, disciplinary procedures will be applied.
Implementation of the Background Screening Policy is the responsibility of the Human Resources Manager.
James and Julie Phillpot
Hydrocare Leisure Limited
Dated: January 2021